In our January 5, 2026, blog post, we shared the Environmental Protection Agency (EPA) memorandum “Reinforcing ‘Compliance First’ Orientation for Compliance Assurance and Civil Enforcement Activities.”  This memo suggested a different approach to environmental compliance and enforcement.

So, 18 months into President Trump’s second term, what is the current snapshot of environmental enforcement?  We now have some environmental enforcement data from the EPA to digest.

EPA Enforcement Results

In February of this year, the EPA released the Enforcement and Compliance Assurance Annual Results Report for Fiscal Year 2025.

In the report, the EPA states that the program achieved remarkable results.  It concluded with 2,127 civil enforcement cases, the highest number in nine years.  The EPA also obtained commitments totaling more than $6.4 billion to return facilities to compliance and assessed more than $652 million in civil penalties.

However, as reported by Environment and Energy Leader, “Those numbers are real. They are also, in significant part, a function of a single case.  Hino Motors pleaded guilty in March 2025 to a multi-year conspiracy to falsify emissions data and illegally import non-compliant engines into the United States. The resolution included a $521 million criminal fine, a $525 million civil penalty, and an estimated $300 million in additional remediation commitments.”

Additionally, as some of these efforts began under the previous administration, we may have to wait to see what the 2026 enforcement results look like before getting a clearer sense of enforcement efforts under President Trump 2.0.

See the EPA Report, “Enforcement and Compliance Assurance Annual Results Report Fiscal Year 2025.”

Environmental Enforcement Has Not Disappeared

With the above said, the compliance-first memo also states that the EPA Office of Environmental Compliance Assurance is prioritizing “civil judicial and administrative enforcement activities in the most efficient, most economical, and swiftest means possible” (our emphasis).

Below we look at some recent noteworthy environmental enforcement news.

More than 20 Years in the Making:  Poultry Integrators’ $44 Million Agreement

As reported by Farm Progress, “A nearly $44 million new agreement has been reached between the state of Oklahoma and major poultry integrators to settle a long-running lawsuit over pollution of the Illinois River Watershed region of Oklahoma and Arkansas with phosphorus resulting from poultry litter runoff.”

The case dates back to June 13, 2005, when Plaintiffs filed a civil complaint alleging that Defendants degraded and impaired the lands, waters, and other natural resources of the Illinois River Watershed (IRW).

According to court documents, Defendants include Tyson Foods, Inc.; Tyson Poultry, Inc.; Tyson Chicken, Inc.; Cobb-Vantress, Inc.; Cal-Maine Foods, Inc.; Cargill Incorporated; Cargill Turkey Production, LLC; George’s, Inc.; George’s Farms, Inc.; Peterson Farms, Inc.; and Simmons Foods, Inc.

EPA Complaint Against Wego Chemical Group for Toxic Substances Control Act Violations

Further to our June 8, 2026, blog regarding the Toxic Substances Control Act (TSCA) violations at Wego Chemical Group of Great Neck, NY, and related companies.

The nearly 100-page complaint from the EPA includes the following six counts (Note: Source for information below also includes blog by Burgeson and Campbell):

• Count 1: TSCA Section 8(a):  Failure to Submit 2020 Form U for 209 Reportable Chemical Substances (25,000-pound threshold).  EPA seeks a penalty of up to $49,772 for each of the 209 chemicals listed in the 2020 Form U that Wego failed to submit in a timely manner.
• Count 2: TSCA Section 8(a):  Failure to Submit 2020 Form U Chemical Data Report for Five Reportable Chemical Substances (2,500-pound threshold).  EPA seeks a penalty of up to $49,772 for each of these five chemical substances listed in the 2020 Form U that Wego failed to submit in a timely manner.
• Count 3: TSCA Section 8(a):  Failure to Report Required Information in 2020 Form U.  EPA seeks a penalty of up to $49,772 for each of the 209 chemical substances for which Wego failed to report required information.
• Count 4: TSCA Section 8(a):  Failure to Report Required Information in 2024 Form U.  EPA seeks a penalty of up to $49,772 for each of the 247 chemical substances for which Wego failed to report required information.
• Count 5: Seven Pre-Manufacture Notice Violations for each of the seven alleged PMN violations.  EPA seeks a penalty of up to $49,772 for each of the seven alleged PMN violations.
• Count 6: Failure to Provide Requisite TSCA Certifications for TCA Importations.  EPA seeks a penalty of up to $49,772 for each of the seven alleged certification violations.

Burgeson and Campbell state, “If the 684 counts hold and maximum penalties are sought, the EPA’s enforcement matter against Wego could yield a massive $34 million penalty for alleged violations of TSCA – the vast majority of which involve violations for lack of reporting under EPA’s CDR (Chemical Data Reporting) rule” (our emphasis).

Favorable Environment to Disclose and Resolve

It appears that the EPA is interested in getting companies into compliance promptly but has no patience for deliberate falsification of compliance data and intentional fraud.  However, with the focus on compliance over enforcement, this remains a favorable environment for conducting an environmental compliance assessment.

From the Environment and Energy Leader:  “EPA’s voluntary disclosure programs received 538 disclosures covering violations at 957 facilities in fiscal year 2025. Companies running proactive programs are using the favorable environment to disclose and resolve.  Companies that are not running those programs do not have access to the same pathway.”

If you have questions about environmental compliance, contact Matthew Schroeder, P.E. (Ext. 117) or Jeffrey Bolin, CHMM (Ext. 125) at 248-932-0228.

Alan Hahn drafted this blog.  Alan has an undergraduate degree in Environmental Studies and completed a graduate program in Environmental Management.  He has worked in environmental management for more than 45 years.  He has written hundreds of blogs and articles.  His published work includes Michigan Lawyers Weekly, Detroiter, Michigan Forward, GreenStone Partners, Manure Manager Magazine, Progressive Dairy, and HazMat Magazine.

Jeffrey Bolin, M.S., reviewed this blog.  Jeff is a partner and senior scientist at Dragun Corporation.  He is a published author, a frequent speaker, and an expert witness.  His expertise in environmental due diligence, PFAS, vapor intrusion, and site assessments has led to projects in the US, Canada, and overseas.  See Jeff’s Bio.  

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